Sanctions and Counter-Terrorism

Discuss the impact of sanctions and counter-terrorism regulations and engage with stakeholders to improve the regulatory framework

Sanctions and counter-terrorism regulations have a significant impact on INGO operations in high-risk environments, including the safe and effective delivery of humanitarian aid, and the creation of space for dialogue and mediation. 

These programmes often take place in areas of conflict or instability, where some actors have been designated as terrorist groups or are subject to sanctions. This poses problems for INGOs seeking to deliver humanitarian aid or peacebuilding actions, who may encounter or need to engage with proscribed groups in the course of their activities.

One unintended consequence is bank de-risking, where banks either refuse to provide financial services, close bank accounts, or stop or delay payments in order to comply with sanctions and counter-terrorism regulations. Incidents of bank de-risking have become increasingly common as banks have become more risk averse, making it harder for INGOs to transfer funds through formal banking channels to support operations overseas.

Members of this group discuss the impact of sanctions and counter-terrorism regulations on their programmes, and how to mitigate their effects. The group also engages with stakeholders at a national and international level to improve the regulatory framework for INGOs.